Privacy Policy
1. Data Protection at a Glance
General Information
The following notices provide a simple overview of what happens to your personal data when you visit our website or use our application Voicely. Personal data is any data with which you can be personally identified. Detailed information on the subject of data protection can be found in our privacy policy set out below this text.
Data Collection on Our Website and in Voicely
Who is responsible for the data processing?
The data processing is carried out by the operator of the website and the application Voicely. You can find their contact details in the section “Information on the Data Controller” in this privacy policy.
How do we collect your data?
On the one hand, your data is collected when you provide it to us. This may, for example, be data that you enter during registration, in a contact form, or when using the application.
Other data is collected automatically or after your consent when you use our website or the application, by means of our IT systems. This is primarily technical data (e.g. operating system, device type, or time of use). This data is collected automatically as soon as you visit our website or use the application.
When using Voicely, audio data is also collected in order to process your voice input. This data is transmitted to third-party services for transcription and text enhancement. You can find further information on this in the relevant sections of this privacy policy.
What do we use your data for?
Part of the data is collected in order to ensure the error-free provision of the website and the application. Other data is used to provide our transcription and text enhancement services. In addition, data may be used to analyze your user behavior.
What rights do you have regarding your data?
You have the right at any time to receive information about the origin, recipients, and purpose of your stored personal data free of charge. You also have a right to request the rectification or erasure of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. In addition, you have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You can contact us at any time regarding this and other questions on the subject of data protection.
Analysis Tools and Third-Party Tools
When you use our website or our application, your usage behavior may be analyzed statistically. This is done primarily by means of so-called analysis programs.
Detailed information on these analysis programs can be found in the following privacy policy.
2. Hosting and Backend Services
We host the content of our website and operate the backend infrastructure of our application with the following providers:
Vercel
The provider is Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA (hereinafter Vercel). Our website is hosted and provided via the Vercel platform. When you visit our website, your personal data is processed on Vercel’s servers. In this process, personal data may also be transferred to the USA.
For details, please refer to Vercel’s privacy policy: https://vercel.com/legal/privacy-policy
The use of Vercel is based on Art. 6 (1) (f) GDPR. We have a legitimate interest in providing our website as reliably as possible. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG (German Telecommunications Digital Services Data Protection Act), insofar as the consent covers the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find further information here: https://vercel.com/legal/privacy-policy
Supabase
The provider is Supabase Inc., 970 Toa Payoh North #07-04, Singapore 318992 (hereinafter Supabase). Supabase provides the database and authentication services for our application Voicely. Your data is processed on servers in the European Union (Frankfurt, Germany).
For details, please refer to Supabase’s privacy policy: https://supabase.com/privacy
The use of Supabase is based on Art. 6 (1) (b) GDPR, as the processing is necessary for the performance of the usage contract of our application. In addition, we base the processing on our legitimate interest in the secure and reliable provision of our services pursuant to Art. 6 (1) (f) GDPR.
ElevenLabs
The provider is ElevenLabs Inc., 1732 1st Ave #20667, New York, NY 10128, USA (hereinafter “ElevenLabs”). ElevenLabs provides the speech-to-text service for our application Voicely. When you use the dictation function in Voicely, your audio data is transmitted to ElevenLabs servers within the European Union for transcription (EU endpoint). The audio data is used exclusively to perform the transcription and is not permanently stored by ElevenLabs. No transfer to third countries takes place.
A data processing agreement (DPA) pursuant to Art. 28 GDPR has been concluded with ElevenLabs, which ensures the data-protection-compliant processing of your data.
For details, please refer to ElevenLabs’ privacy policy: https://elevenlabs.io/privacy
The use of ElevenLabs is based on Art. 6 (1) (b) GDPR, as the processing is necessary for the provision of the contractually agreed transcription service.
Nebius Token Factory
The provider is Nebius B.V., Schiphol Boulevard 165, 1118 BG Schiphol, Netherlands (hereinafter “Nebius”). Nebius provides the AI-assisted text enhancement for our application Voicely via its Token Factory API. When you use the dictation function, the transcribed text is transmitted to the Nebius Token Factory API for linguistic enhancement. We configure the processing via an EU endpoint and use the protective measures provided for in Nebius’ contractual and data protection documents.
The technical configuration of the Voicely cloud pipeline for AI-assisted text enhancement is restricted to the Nebius Token Factory endpoint api.tokenfactory.nebius.com, the region eu-north1, and the model openai/gpt-oss-120b. Other Token Factory region hosts, in particular us-central1, are technically blocked in the Voicely LLM path.
For details, please refer to Nebius’ privacy policy and data processing agreement: https://docs.nebius.com/legal/privacy and https://docs.tokenfactory.nebius.com/legal/dpa
The use of the Nebius Token Factory API is based on Art. 6 (1) (b) GDPR, as the processing is necessary for the provision of the contractually agreed text enhancement service.
3. General Information and Mandatory Notices
Data Protection
The operators of this website and the application Voicely take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations as well as this privacy policy.
When you use our website or our application Voicely, various personal data is collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.
We point out that data transmission over the internet (e.g. when communicating by email) can have security gaps. Complete protection of the data against access by third parties is not possible.
Information on the Data Controller
The controller responsible for data processing on this website and in the application Voicely is:
RelationFlow Ltd.
Anthypolochagou Georgiou M. Savva 26, Office 1-2
8201 Paphos, Cyprus (CY)
Email: support@voicely.de
The data controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).
Data Protection Officer
We have appointed a data protection officer for our company.
NUM3RUS GmbH
Carmenstr. 9
40549 Düsseldorf
Phone: +49 2131 2022471
Email: support@voicely.de
Storage Period
Unless a more specific storage period is stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for erasure or revoke consent to data processing, your data will be deleted, unless we have other legally permissible grounds for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the deletion will take place once these grounds cease to apply.
General Information on the Legal Bases for Data Processing
Insofar as you have consented to the data processing, we process your personal data on the basis of Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, insofar as special categories of data pursuant to Art. 9 (1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also carried out on the basis of Art. 49 (1) (a) GDPR. Insofar as you have consented to the storage of cookies or to access to information in your end device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of Section 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the performance of a contract or for carrying out pre-contractual measures, we process your data on the basis of Art. 6 (1) (b) GDPR. Furthermore, we process your data insofar as it is necessary for compliance with a legal obligation, on the basis of Art. 6 (1) (c) GDPR. The data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 (1) (f) GDPR. Information on the legal bases relevant in each individual case is provided in the following paragraphs of this privacy policy.
Information on Data Transfer to Third Countries That Are Not Secure Under Data Protection Law as Well as Transfer to US Companies That Are Not DPF-Certified
Among other things, we use tools from companies based in third countries that are not secure under data protection law, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). When these tools are active, your personal data may be transferred to and processed in these countries. We point out that in third countries that are not secure under data protection law, no level of data protection comparable to that of the EU can be guaranteed.
We point out that the USA, as a secure third country, generally has a level of data protection comparable to that of the EU. A data transfer to the USA is therefore permissible if the recipient holds a certification under the “EU-US Data Privacy Framework” (DPF) or has suitable additional guarantees. Information on transfers to third countries, including the data recipients, can be found in this privacy policy.
Recipients of Personal Data
In the course of our business activities, we work with various external bodies. In some cases, a transfer of personal data to these external bodies is also required. We only pass on personal data to external bodies if this is necessary within the scope of the performance of a contract, if we are legally obliged to do so (e.g. passing data on to tax authorities), if we have a legitimate interest pursuant to Art. 6 (1) (f) GDPR in the transfer, or if another legal basis permits the data transfer. When using data processors, we only pass on our customers’ personal data on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.
Revocation of Your Consent to Data Processing
Many data processing operations are only possible with your explicit consent. You can revoke consent that has already been given at any time. The lawfulness of the data processing carried out up to the revocation remains unaffected by the revocation.
Right to Object to Data Collection in Special Cases and to Direct Advertising (Art. 21 GDPR)
IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 (1) (E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES TO ASSERT, EXERCISE, OR DEFEND LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 (1) GDPR).
IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT ADVERTISING (OBJECTION PURSUANT TO ART. 21 (2) GDPR).
Right to Lodge a Complaint with the Competent Supervisory Authority
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged violation. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.
Right to Data Portability
You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.
Access, Rectification, and Erasure
Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of the data processing, and, where applicable, a right to rectification or erasure of this data. You can contact us at any time regarding this and other questions on the subject of personal data.
Right to Restriction of Processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:
- If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data was/is unlawful, you can request the restriction of the data processing instead of erasure.
- If we no longer need your personal data but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
- If you have lodged an objection pursuant to Art. 21 (1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data may – apart from its storage – only be processed with your consent or for the assertion, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.
SSL or TLS Encryption
For security reasons and to protect the transmission of confidential content, our website and the communication between the application Voicely and our servers use SSL or TLS encryption. On the website, you can recognize an encrypted connection by the fact that the address bar of the browser changes from “http://” to “https://” and by the lock symbol in your browser bar.
When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Objection to Advertising Emails
We hereby object to the use of contact data published within the scope of the legal-notice obligation for the purpose of sending advertising and information materials that have not been expressly requested. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, for example by means of spam emails.
4. Data Collection on Our Website and in Voicely
Cookies
Our website uses so-called “cookies”. Cookies are small data packets and do not cause any damage to your end device. They are stored on your end device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or until they are automatically deleted by your web browser.
Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies within websites (e.g. cookies for analyzing user behavior).
Cookies have various functions. Numerous cookies are technically necessary, since certain website functions would not work without them. Other cookies can be used to analyze user behavior or for advertising purposes.
Cookies that are necessary to carry out the electronic communication process, to provide certain functions you have requested, or to optimize the website (e.g. cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6 (1) (f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in the storage of necessary cookies for the technically error-free and optimized provision of its services. Insofar as consent to the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG); the consent can be revoked at any time.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of our website may be limited.
Which cookies and services are used on our website can be found in this privacy policy.
Contact Form
If you send us inquiries via the contact form, your details from the inquiry form, including the contact data you provide there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We do not pass on this data without your consent.
The processing of this data is carried out on the basis of Art. 6 (1) (b) GDPR, insofar as your inquiry is related to the performance of a contract or is necessary for carrying out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the inquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR) insofar as this has been requested; the consent can be revoked at any time.
The data you enter in the contact form will remain with us until you ask us to delete it, revoke your consent to storage, or the purpose for the data storage no longer applies (e.g. after the processing of your inquiry has been completed). Mandatory statutory provisions – in particular retention periods – remain unaffected.
Inquiry by Email, Telephone, or Fax
If you contact us by email, telephone, or fax, your inquiry, including all resulting personal data (name, inquiry), will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.
The processing of this data is carried out on the basis of Art. 6 (1) (b) GDPR, insofar as your inquiry is related to the performance of a contract or is necessary for carrying out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the inquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR) insofar as this has been requested; the consent can be revoked at any time.
The data you send to us via contact inquiries will remain with us until you ask us to delete it, revoke your consent to storage, or the purpose for the data storage no longer applies (e.g. after the processing of your request has been completed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
Registration and User Account in Voicely
You can create a user account in our application Voicely. For this purpose, the data requested during registration (e.g. email address) is collected and processed. Registration is required to use the application.
The processing is carried out on the basis of Art. 6 (1) (b) GDPR, as registration is necessary for the performance of the usage contract.
The data collected during registration is stored by us for as long as you are registered in our application and is subsequently deleted. Mandatory statutory retention periods remain unaffected.
Processing of Voice and Audio Data in Voicely
When using the dictation function in Voicely, your voice input is recorded via your device’s microphone. The audio recordings are transmitted to the ElevenLabs service for transcription, and the resulting text is transmitted to the Nebius Token Factory API for linguistic enhancement. For the text enhancement, the Nebius LLM provider is technically restricted to the EU endpoint eu-north1. The audio data is used exclusively to perform the transcription and is not permanently stored by the respective service providers after the processing has been completed.
The transcribed and enhanced texts are stored in your user account in order to provide you with a transcription history.
The processing is carried out on the basis of Art. 6 (1) (b) GDPR, as it is necessary for the provision of the contractually agreed transcription and text enhancement service.
5. Social Media
Elements of the social network Facebook are integrated on our website. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. However, according to Facebook, the collected data is also transferred to the USA and to other third countries.
You can find an overview of the Facebook social media elements here: https://developers.facebook.com/docs/plugins/?locale=de_DE
When the social media element is active, a direct connection is established between your end device and the Facebook server. Facebook thereby receives the information that you have visited our website with your IP address. If you click the Facebook “Like” button while logged into your Facebook account, you can link the content of our website to your Facebook profile. This allows Facebook to associate the visit to our website with your user account. We point out that, as the provider of the pages, we do not obtain any knowledge of the content of the transmitted data or its use by Facebook. You can find further information on this in Facebook’s privacy policy at: https://de-de.facebook.com/privacy/explanation
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
Insofar as personal data is collected on our website and forwarded to Facebook with the help of the tool described here, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing carried out by Facebook after the forwarding is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. You can find the wording of the agreement at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the data protection information when using the Facebook tool and for the data-protection-compliant implementation of the tool on our website. Facebook is responsible for the data security of the Facebook products. You can assert data subject rights (e.g. requests for information) regarding the data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://de-de.facebook.com/help/566994660333381 and https://www.facebook.com/policy.php
The company holds a certification under the “EU-US Data Privacy Framework” (DPF). You can obtain further information on this from the provider at the following link: https://www.dataprivacyframework.gov
X (formerly Twitter)
Functions of the service X (formerly Twitter) are integrated on our website. These functions are offered by the parent company X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. For the data processing of persons living outside the USA, the branch Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, is responsible.
When the social media element is active, a direct connection is established between your end device and the X server. X (formerly Twitter) thereby receives information about your visit to our website. By using X (formerly Twitter) and the “Re-Tweet” or “Repost” function, the websites you visit are linked to your X (formerly Twitter) account and made known to other users. You can find further information on this in the privacy policy of X (formerly Twitter) at: https://twitter.com/de/privacy
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://gdpr.twitter.com/en/controller-to-controller-transfers.html
You can change your data protection settings on X (formerly Twitter) in the account settings at https://twitter.com/account/settings.
Functions of the Instagram service are integrated on our website. These functions are offered by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
When the social media element is active, a direct connection is established between your end device and the Instagram server. Instagram thereby receives information about your visit to our website.
If you are logged into your Instagram account, you can link the content of our website to your Instagram profile by clicking the Instagram button. This allows Instagram to associate the visit to our website with your user account.
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
Insofar as personal data is collected on our website and forwarded to Facebook or Instagram with the help of the tool described here, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook or Instagram. You can find the wording of the agreement at: https://www.facebook.com/legal/controller_addendum
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://privacycenter.instagram.com/policy/ and https://de-de.facebook.com/help/566994660333381
The company holds a certification under the “EU-US Data Privacy Framework” (DPF). You can obtain further information on this from the provider at the following link: https://www.dataprivacyframework.gov
Our website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Each time a page of our website that contains LinkedIn elements is accessed, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited our website with your IP address. If you click the “Recommend” button of LinkedIn and are logged into your LinkedIn account, LinkedIn is able to associate your visit to our website with you and your user account.
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://www.linkedin.com/help/linkedin/answer/a1343190
You can find further information on this in LinkedIn’s privacy policy at: https://www.linkedin.com/legal/privacy-policy
6. Analysis Tools and Advertising
Google Tag Manager
We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Tag Manager is a tool that allows us to integrate tracking or statistics tools and other technologies on our website. Google Tag Manager itself does not create any user profiles, does not store any cookies, and does not carry out any independent analyses. It merely serves to manage and deliver the tools integrated via it. However, Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.
The use of Google Tag Manager is based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the quick and straightforward integration and management of various tools on its website. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG, insofar as the consent covers the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time.
The company holds a certification under the “EU-US Data Privacy Framework” (DPF). You can obtain further information on this from the provider at the following link: https://www.dataprivacyframework.gov
Google Analytics
Our website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior of website visitors. In this process, the website operator receives various usage data, such as page views, time spent, operating systems used, and the origin of the user. This data is assigned to the respective end device of the user. No assignment to a user ID takes place.
Furthermore, with Google Analytics we can record, among other things, your mouse and scroll movements and clicks. In addition, Google Analytics uses various modeling approaches to supplement the collected data sets and employs machine learning technologies in the data analysis.
Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of our website is generally transferred to a Google server in the USA and stored there.
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://privacy.google.com/businesses/controllerterms/mccs/
The company holds a certification under the “EU-US Data Privacy Framework” (DPF). You can obtain further information on this from the provider at the following link: https://www.dataprivacyframework.gov
IP Anonymization
Google Analytics IP anonymization is activated. As a result, your IP address is shortened by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there.
Browser Plugin
You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de
You can find more information about how Google Analytics handles user data in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de
PostHog
We use PostHog in our application Voicely. The provider is PostHog Inc., 2261 Market Street #4008, San Francisco, CA 94114, USA (hereinafter PostHog).
PostHog enables us to analyze usage behavior within our application and to improve the user experience. In this process, usage data such as functions accessed, interactions, time spent, operating systems used, and device types is collected.
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR. The consent can be revoked at any time. Alternatively, we base the processing on our legitimate interest in the analysis and improvement of our application pursuant to Art. 6 (1) (f) GDPR.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. For further information, please refer to PostHog’s privacy policy: https://posthog.com/privacy
Sentry
We use Sentry in our application Voicely. The provider is Functional Software Inc. (d/b/a Sentry), 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA (hereinafter Sentry).
Sentry serves to detect and analyze software errors in our application. When an error occurs, technical data such as error messages, stack traces, operating system, device type, and app version is transmitted to Sentry. This data is used exclusively for error correction and quality assurance.
The use of Sentry is based on our legitimate interest in the stability and error-free operation of our application pursuant to Art. 6 (1) (f) GDPR.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. For further information, please refer to Sentry’s privacy policy: https://sentry.io/privacy/
Google Ads
The website operator uses Google Ads. Google Ads is an online advertising program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms on Google (keyword targeting). Furthermore, targeted advertisements can be displayed based on the user data available at Google (e.g. location data and interests) (audience targeting).
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://policies.google.com/privacy/frameworks and https://business.safety.google/controllerterms/
Google AdSense
Our website uses Google AdSense, a service for integrating advertisements. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google AdSense uses cookies, web beacons (invisible graphics), and comparable recognition technologies. These can be used to analyze information such as visitor traffic on these pages.
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
Google Ads Remarketing
Our website uses the functions of Google Ads Remarketing. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With Google Ads Remarketing, we can assign persons who interact with our online offering to specific target groups in order to subsequently display interest-based advertising to them in the Google advertising network (remarketing or retargeting).
If you have a Google account, you can object to personalized advertising at the following link: https://adssettings.google.com/anonymous?hl=de
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
You can find further information and the data protection provisions in Google’s privacy policy at: https://policies.google.com/technologies/ads?hl=de
Google Conversion Tracking
Our website uses Google Conversion Tracking. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With the help of Google Conversion Tracking, Google and we can recognize whether the user has carried out certain actions. We do not receive any information with which we can personally identify the user. Google itself uses cookies or comparable recognition technologies for identification.
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
You can find more information about Google Conversion Tracking in Google’s data protection provisions: https://policies.google.com/privacy?hl=de
Meta Pixel (formerly Facebook Pixel)
Our website uses the visitor action pixel of Facebook/Meta for conversion measurement. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the collected data is also transferred to the USA and to other third countries.
This makes it possible to track the behavior of site visitors after they have been redirected to the provider’s website by clicking on a Facebook advertisement. This allows the effectiveness of Facebook advertisements to be evaluated for statistical and market research purposes and future advertising measures to be optimized.
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
In Facebook’s data protection notices, you can find further information on the protection of your privacy: https://de-de.facebook.com/about/privacy/
Facebook Conversion API
We have integrated the Facebook Conversion API on our website. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.
The Facebook Conversion API enables us to record the website visitor’s interactions with our website and pass them on to Facebook in order to improve the advertising performance on Facebook.
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
Facebook Custom Audiences
We use Facebook Custom Audiences. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.
When you visit our website or use our application Voicely, use our free or paid offerings, transmit data to us, or interact with our company’s Facebook content, we collect your personal data in this process. Insofar as you grant us consent to use Facebook Custom Audiences, we will transmit this data to Facebook, with which Facebook can display suitable advertising to you.
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
TikTok Pixel
We have integrated the TikTok Pixel on our website. The provider is TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland (hereinafter TikTok).
With the help of the TikTok Pixel, we can display interest-based advertising on TikTok (TikTok Ads) to website visitors who have viewed our offerings. At the same time, with the help of the TikTok Pixel, we can determine how effective our advertising on TikTok is.
The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. The consent can be revoked at any time.
The data transfer to third countries is based on the standard contractual clauses of the EU Commission. You can find details here: https://www.tiktok.com/legal/page/eea/privacy-policy/de-DE and https://ads.tiktok.com/i18n/official/policy/controller-to-controller
LinkedIn Insight Tag
Our website uses the LinkedIn Insight Tag. The provider of this service is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
With the help of the LinkedIn Insight Tag, we receive information about the visitors to our website. If a website visitor is registered with LinkedIn, we can, among other things, analyze the professional key data of our website visitors and thus better align our site with the respective target groups. Furthermore, with the help of LinkedIn Insight Tags, we can measure whether the visitors to our websites make a purchase or another action (conversion measurement).
Insofar as consent has been obtained, the use of the above-mentioned service is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 TDDDG. The consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs
You can object to the analysis of usage behavior and targeted advertising by LinkedIn at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
7. Plugins and Tools
YouTube
Our website embeds videos from the YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
When you visit one of our web pages on which YouTube is embedded, a connection to the YouTube servers is established. In this process, the YouTube server is informed which of our pages you have visited.
Furthermore, YouTube can store various cookies on your end device or use comparable recognition technologies (e.g. device fingerprinting). In this way, YouTube can obtain information about visitors to our website.
If you are logged into your YouTube account, you enable YouTube to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.
The use of YouTube is in the interest of an appealing presentation of our online offerings. This constitutes a legitimate interest within the meaning of Art. 6 (1) (f) GDPR. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG, insofar as the consent covers the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time.
You can find further information on the handling of user data in YouTube’s privacy policy at: https://policies.google.com/privacy?hl=de
Google Fonts
For the uniform display of fonts, our website uses so-called Google Fonts, which are provided by Google. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When you access a page, your browser loads the required fonts into its browser cache in order to display texts and fonts correctly.
For this purpose, the browser you use must connect to Google’s servers. As a result, Google becomes aware that our website was accessed via your IP address. The use of Google Fonts is based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the uniform display of the typeface on its website. Insofar as corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG, insofar as the consent covers the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time.
If your browser does not support Google Fonts, a standard font from your computer is used.
You can find further information on Google Fonts at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=de
8. Newsletter
Newsletter Data
If you would like to receive the newsletter offered on our website, we require an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. For the handling of the newsletter, we use newsletter service providers, who are described below.
ActiveCampaign
Our website uses ActiveCampaign for sending newsletters. The provider is ActiveCampaign, Inc., 1 N Dearborn, 5th Floor Chicago, Illinois 60602, USA.
ActiveCampaign is a service with which, among other things, the sending of newsletters can be organized and analyzed. The data you enter for the purpose of receiving the newsletter is stored on ActiveCampaign’s servers in the USA.
With the help of ActiveCampaign, it is possible for us to analyze our newsletter campaigns. For example, we can see whether a newsletter message was opened and which links were clicked, if any. If you do not want any analysis by ActiveCampaign, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.
The data processing is carried out on the basis of your consent (Art. 6 (1) (a) GDPR). You can revoke this consent at any time. The lawfulness of the data processing operations already carried out remains unaffected by the revocation.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find detailed information on the functions of ActiveCampaign at the following link: https://www.activecampaign.com/email-marketing
You can find ActiveCampaign’s privacy policy at: https://www.activecampaign.com/privacy-policy
Klick-Tipp
Our website uses Klick-Tipp for sending newsletters. The provider is KLICK-TIPP LIMITED, 15 Cambridge Court, 210 Shepherd's Bush Road, London W6 7NJ, United Kingdom.
Klick-Tipp is a service with which, among other things, the sending of newsletters can be organized and analyzed. When we send newsletters with the help of Klick-Tipp, we can determine whether a newsletter message was opened and which links were clicked, if any.
If you do not want any analysis by Klick-Tipp, you must therefore unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.
The data processing is carried out on the basis of your consent (Art. 6 (1) (a) GDPR). You can revoke this consent at any time.
For details, please refer to Klick-Tipp’s data protection provisions at: https://www.klicktipp.com/datenschutzerklarung/
Newsletter Mailing to Existing Customers
If you order goods or services from us and provide your email address in this process, this email address may subsequently be used by us for sending newsletters, provided that we inform you about this in advance. In such a case, only direct advertising for our own similar goods or services is sent via the newsletter. You can cancel the receipt of this newsletter at any time. In this case, the legal basis for sending the newsletter is Art. 6 (1) (f) GDPR in conjunction with Section 7 (3) UWG (German Act Against Unfair Competition).
9. eCommerce and Payment Providers
Processing of Customer and Contract Data
We collect, process, and use personal customer and contract data for the establishment, substantive arrangement, and modification of our contractual relationships. We collect, process, and use personal data about the use of our website and our application Voicely (usage data) only insofar as this is necessary to enable the user to make use of the service or to bill for it. The legal basis for this is Art. 6 (1) (b) GDPR.
The collected customer data is deleted after completion of the order or termination of the business relationship and expiry of any existing statutory retention periods. Statutory retention periods remain unaffected.
Data Transfer Upon Conclusion of a Contract for Services and Digital Content
We transmit personal data to third parties only if this is necessary within the scope of the contract processing, for example to the credit institution commissioned with the payment processing.
No further transmission of the data takes place, or only if you have expressly consented to the transmission. Your data is not passed on to third parties without express consent, for example for advertising purposes.
The basis for the data processing is Art. 6 (1) (b) GDPR, which permits the processing of data for the performance of a contract or pre-contractual measures.
Payment Services
We integrate payment services of third-party companies on our website and in our application. When you make a purchase with us, your payment data (e.g. name, payment amount, bank account details, credit card number) is processed by the payment service provider for the purpose of payment processing. The respective contractual and data protection provisions of the respective providers apply to these transactions. The use of the payment service providers is based on Art. 6 (1) (b) GDPR (contract processing) and in the interest of a payment process that is as smooth, convenient, and secure as possible (Art. 6 (1) (f) GDPR).
Stripe
The provider of this payment service is Stripe Inc., 354 Oyster Point Blvd, South San Francisco, CA 94080, USA. For the data processing of persons residing in the EU, Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland, is responsible.
When you make a payment via Stripe, the payment data you enter (e.g. name, email address, credit card number, payment amount) is transmitted to Stripe and processed there. Stripe uses this data for payment processing and fraud prevention. In this process, data may also be transferred to the parent company in the USA.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://stripe.com/de/legal/dpa
For details, please refer to Stripe’s privacy policy: https://stripe.com/de/privacy
The company holds a certification under the “EU-US Data Privacy Framework” (DPF). You can obtain further information on this from the provider at the following link: https://www.dataprivacyframework.gov